CALIFORNIA PRIVACY RIGHTS

Last Updated: November 18, 2021

The information in this California Privacy Rights Statement (“California Statement”) supplements the information in our Privacy Statement. This California Statement provides additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).

Unless otherwise expressly stated, all terms in this California Statement have the same meaning as defined in our Privacy Statement or as otherwise defined in the CCPA.

Categories of personal data we collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household (“personal data”). In particular, we have collected one or more data types in the following categories of personal data from consumers within the twelve (12) months preceding the effective date of this Privacy Statement:

Category One or More Data Types Collected?
A. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. Yes
B. Any categories of personal data described in Cal. Civ. Code § 1798.80(e), such as name, physical characteristics or description, address, telephone number, credit card number, debit card number, or any other financial information, medical information. Yes
C. Characteristics of protected classifications under California or federal law. Yes
D. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes
E. Sleep, health, or exercise data that contain identifying information. Yes
F. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. Yes
G. Geolocation data Yes
H. Audio, electronic, visual, thermal, olfactory, or similar information. Yes
I. Professional or employment-related information. No
J. Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes

For additional information, see Information We Collect About You.

Categories of sources of personal data

We obtain the categories of personal data listed above from the following categories of sources:

  • Directly from our consumers (for example, information provided through the Website, or other communications with us).
  • From consumers’ activity on the Services (for example, Website visit information collected directly or through third-party analytics providers).
  • From a device’s GPS, Wi-Fi, Bluetooth, or IP address.
  • From social networks, marketing partners, advertising networks, data analytics providers, internet service providers, operating systems and platforms, data brokers, payment processors, and other sources (for example, affiliates, public and third-party databases, and other third parties, such as business customers/clients).

For additional information, see Information We Collect About You.

Our business and commercial purposes for collecting personal data

We use the personal data we collect for our operational purposes or other purposes set out in our Privacy Statement (See How We Use Your Information). Those purposes may include:

  • To provide and maintain our Services.
  • To establish and maintain our busines relationship with you.
  • To notify you about changes to our Services.
  • To communicate with you about your use of our Services, including to send you reminders, to respond to your inquiries, and for other customer service purposes.
  • To tailor the content and information that we may send or display to you, to offer location customization and personalized help and instructions, and to otherwise personalize your experiences while using the Services. We also leverage the information we collect in aggregate to deliver more relevant advertisements and offers to you on other third-party websites as you navigate the Internet.
  • To provide you with information that we believe to be of interest to you, including health or wellness-related information or services.
  • To send you e-mail marketing materials about our products and services.
  • To send you news and newsletters.
  • To better understand how users access and use our Services, both on an aggregated and individualized basis.
  • To handle inquiries and complaints you or other users of our Services submit to us.
  • To administer surveys and questionnaires, such as for market research or user satisfaction purposes, and for obtaining health and wellness information.
  • To comply with legal obligations, as part of our general business operations, and for other business administration purposes, such as maintaining customer records, monitoring your compliance with any of your agreements with us, collecting debts owed to us, and safeguarding our business interests.
  • To verify that you meet the eligibility requirements for purchasing or receiving our Services.
  • Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, and in situations involving potential threats to the safety of any person or violations of our Terms of Use or our Privacy Statement.
  • For research and analytics purposes, including analyzing data, identifying trends and issues and creating statistical reports, analyzing the accuracy and effectiveness of our Website and the Services, including administering, troubleshooting, and enhancing and improving the Website and the Services.
  • For quality assurance and regulatory compliance purposes
  • To fulfill any other purpose for which you provide the information.
  • For any other purpose for which we provide you notice, or you provide us with your consent.

In the twelve (12) months preceding the effective date of this California Statement, we have disclosed one or more data types in the following categories of personal data of California consumers for a business purpose, including for the purpose of directly or indirectly enabling or effecting commercial transactions:

Category A: Identifiers.
Category B: Categories of personal data described in Cal. Civ. Code § 1798.80(e).
Category C: Characteristics of protected classifications under California or federal law.
Category F: Internet or other electronic network activity information.
Category G: Geolocation data.
Category H: Audio, electronic, visual, thermal, olfactory, or similar information.
Category K: Inferences drawn from other personal data.

We also use the personal data we collect for our commercial or economic purposes, such as attracting consumers to buy, subscribe to, provide, or exchange products, goods, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.

Categories of third parties with whom we share personal data

For information on where we share personal data, see How we share your information.

We may from time to time, and we have in the last 12 months, exchanged contact information (Identifiers and CA Customer Records) we maintain for contact information our promotional and marketing partners maintain, which would constitute a “sale” as defined under the CCPA. In addition, as is common practice among companies that operate online, we do allow certain third-party partners and providers to collect information about consumers directly through our services for purposes of analyzing and optimizing our services, delivering ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. For more information about how to opt out of personal information sharing that constitutes a “sale” under the CCPA, please refer to the Rights of California residents’ section below.

Rights of California residents

Right to Request Disclosure. If you are a California consumer, you have the right to request, free of charge, that we disclose information about our collection and use of your personal information over the past twelve (12) months, including:

  1. The categories of personal information we collect about you;
  2. What personal information we collect, use, or disclose about you;
  3. The categories of sources of the personal information we collect about you;
  4. Our business or commercial purpose for collecting the personal information;
  5. For each category of personal information, the categories of third parties with whom it was disclosed; and
  6. The specific pieces of personal information we collect about you.

For more information on how to request information about our collection, use, and disclosure of your personal information, please see the Submitting CCPA Requests section below.

Right to Request Deletion. You have the right to request the deletion of your personal information that we collected. For more information on how to request deletion, please see the Submitting CCPA Requests below. Once we receive your request and verify your identity, we will review your request to see if an exception allowing us to retain the information applies. We will delete or de-identify personal information not subject to an applicable exception from our records and will direct our service providers to take similar action.

You do not need to create an account with us to exercise your deletion rights. We will only use personal information provided in a deletion request to review and comply with the request.

Right to Request Opt-Out of the Sale of Your Personal Information. If you are age 16 or older, you have the right to direct us to not sell your personal information at any time. We do not sell the personal information of consumers we actually know are less than 16 years old.

To exercise the right to opt-out, you or your authorized representative may submit an opt-out request by following the procedures specified in the Submitting CCPA Requests section below. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorized personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing us.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Right of Non-Discrimination. You have the right to be free from discriminatory adverse treatment for exercising these rights. We will not discriminate against you for exercising any of your CCPA rights.

Submitting CCPA Requests

Requests to Know or Delete. To exercise your rights to know or delete described above, you may submit a request by contacting us through one of the following methods:

Requests to Opt-Out of Sales of Your Personal Information. To exercise your right to opt-out of sales of your personal information, you may submit a request form via our website at: https://preferences.takecareof.com/dont_sell. You may also submit a request by emailing us at data-privacy@takecareof.com with the subject line “California Opt-Out.”

Verification of Requests. Only you, or an individual legally authorized to act on your behalf, may make a request to know, delete, or opt-out related to your personal information. To designate an authorized agent, please contact us by using the contact information above.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

  1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, or that the requestor is your authorized representative.
  2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We may request information from you in order to verify your identity. Additionally, we may require that authorized agents provide proof of their authorization. We cannot respond to your request or provide you with personal information if we are unable to verify your identity, your authority to make a request on behalf of another person, or if we cannot confirm that the personal information relates to you. In general, we will verify your request and your identity by matching certain information you provided with the information we have in our records.

You do not need to create an account with us to submit a request to know, or to submit a request to delete your personal information or opt-out of sales of your personal information.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

California’s “Shine the Light” Law

California's "Shine the Light" law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. In order to facilitate these rights, we do not disclose personal information of California residents to third parties for their direct marketing purposes, as defined under California’s “Shine the Light” law, where the resident opts out of such sharing. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law, please fill out the following Right to Opt Out form at: https://preferences.takecareof.com/dont_sell, filling in your first name, last name, and email address, which we need in order to process your request and safeguard your data.

PLEASE NOTE: To opt-out of all disclosures to third parties for direct marketing purposes, you must provide your personal information to be added to our suppression list.

Updates to This California Statement

We will update this California Statement from time to time. When we make changes to this California Statement, we will change the "Last Updated" date at the beginning of this Statement. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions or requests in connection with this California Statement or other privacy-related matters, please send an email to data-privacy@takecareof.com with “California Privacy Statement” in the subject line. Alternatively, inquiries may be addressed to:

NoHo Health Inc.
75 Varick St.
9th Fl ATTN: Care/of
New York, NY 10013